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All large companies at this point have several sets of controls. How well those controls interact is one way to measure the effectiveness of the overall program.

But a lot of times, companies have controls structures that don’t interact, and may not even know of each others’ existence.

Does your program have PEP monitoring? How about OFAC screening? Does your anti-money laundering program conduct KYC? How about M&A Due Diligence?

More than likely, you’re finding things out about third parties, and not knowing it. There’s no reason that your FCPA program can’t leverage your ongoing OFAC screening. If not the program itself, then certainly the tools. How about running you’re current supplier list through your PEP filters? You’ve just gotten a reasonable filter of government organizations that you have to put additional controls around.

I’ve been consistently surprised when you bring everyone together, at least once—and usually more than once—someone says “I didn’t know we were screening that.”